GR L 28534; (July, 1972) (Digest)
G.R. No. L-28534 July 31, 1972
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TANJALALI GAJALI alias TANJA and GOLDAM TOTO alias PABLO, defendants, TANJALALI GAJALI alias TANJA, defendant-appellant.
FACTS
The case involves a robbery in band with homicide and frustrated homicide. Accused-appellant Tanjalali Gajali and his co-accused, Goldam Toto, were charged alongside five other individuals, who remained at large. The prosecution evidence established that on the evening of February 28, 1967, in Busay, Isabela, Basilan City, a group of men, including the appellants, attacked the store and residence of Esteban Maningo. The group had earlier hired a jeepney for a special trip. Upon arrival, they swooped down on the store. Tanjalali Gajali entered first, poking a gun at Epifanio Maquilan and shouting to his companions to go upstairs. Maquilan was then hacked and rendered unconscious. Meanwhile, other members of the group went upstairs, robbed the living quarters of money and valuables exceeding P5,000, and held the occupants at bay. During the incident, Esteban Maningo was found dead with multiple slash wounds.
ISSUE
The primary issue for review is whether the trial court correctly convicted the appellants of the complex crime of robbery in band with homicide and frustrated homicide, specifically concerning the sufficiency of evidence for conspiracy and identification.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the establishment of conspiracy, which renders the act of one the act of all. The Court found conspiracy inferable from the appellants’ coordinated actions: they hired transportation together, changed their destination in unison, alighted at the same location, and executed a concerted attack with distinct roles—some holding victims at bay while others robbed and inflicted violence. This collective purpose and execution substantiate conspiracy without need for a prior explicit agreement.
Consequently, even though there was no direct evidence identifying which specific individual killed Esteban Maningo or which one personally took the stolen articles from the widow, all conspirators are equally liable for the results of the criminal enterprise, including the homicide and the robbery. The Court also upheld the trial court’s rejection of the defenses of alibi and insufficient identification, noting the positive testimonies of witnesses, including the jeepney driver and conductor who identified the appellants as part of the group. The penalty of reclusion perpetua for the complex crime was affirmed, with modifications to the civil indemnities. The indemnity for the death of Esteban Maningo was increased to P12,000, and all civil liabilities were declared joint and several due to the conspiracy.